Modern Slavery Act

SLAVERY AND HUMAN TRAFFICKING STATEMENT

Slavery and Human Trafficking Statement made on behalf of all companies within the ERS Group

INTRODUCTION FROM IAN PARKER, CEO

Modern Slavery is a term used to encompass slavery, servitude, forced or compulsory labour and human trafficking.  Modern slavery is a crime and a violation of human rights.  We have a zero tolerance approach to all forms of slavery and we are committed to ensuring our practices combat modern slavery within our business and in our supply chains. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain.

ORGANISATION’S STRUCTURE

ERS DGB Limited is the holding company for the ERS Group of companies. The main activity of the ERS Group is underwriting motor insurance business at Lloyd’s through its participation in Syndicate 218. The principal subsidiary companies of the ERS Group include ERS Syndicate Management Limited, the Managing Agent for Syndicate 218, and ERS Corporate Member Limited, a corporate member at Lloyd’s which has a significant participation on Syndicate 218. Fellow subsidiary companies ERS Administration Services Limited and ERS Syndicate Services Limited are service companies, respectively providing administration services for the ERS Group and services for Syndicate 218.

The ERS Group has over 700 employees and operates solely in the UK, with offices located in London and Swansea.

OUR BUSINESS

ERS Syndicate Management Limited is the main trading company within the ERS Group. It is authorised by the Prudential Regulation Authority and regulated by the Prudential Regulation Authority and the Financial Conduct Authority. It is also an authorised Lloyd’s Managing Agent, managing the largest motor syndicate at Lloyd’s - Syndicate 218. Its premium income is sourced via a large network of supporting brokers. Its managed syndicate offers a broad range of specialist motor insurance products for the UK personal lines and commercial segments. In 2019 Syndicate 218 is authorised to underwrite £370 million of UK motor business.  

OUR SUPPLY CHAINS

The ERS Group uses 2 sets of suppliers: suppliers who support us in managing motor insurance claims and suppliers who provide routine goods and services such as IT products and cleaning services to support our staff and office operations.

Our procurement activities take place mainly in the UK and our contractors and suppliers are predominantly UK based.

THE ERS GROUP POLICY ON SLAVERY AND HUMAN TRAFFICKING

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. To view the ERS Group Policy on Slavery and Human Trafficking please click here

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

We have evaluated the risk of slavery and human trafficking occurring in our business and in our supply chains, and due to the nature of our business and the locations in which we, our suppliers and brokers operate, we consider the risk to be low. Nevertheless we are committed to maintaining effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains, and we have taken the following steps to enable us to continue identifying, monitoring and addressing potential risks:

  • We have added a section on modern slavery to the Due Diligence Questionnaire we issue to new suppliers. Suppliers are required to describe the steps they have taken to address the risk of slavery and human trafficking. The information obtained enables us to better understand and manage the risks in our supply chain, as well as promoting supplier engagement in this area.
  • As part of our on-boarding process we ask brokers to confirm whether they have a modern slavery policy and procedures in place and whether they provide training in this area to their staff.
  • We have added clauses on modern slavery to both our standard supplier contract and our standard terms of business agreement with brokers. These clauses, amongst other things, prohibit our suppliers and brokers from engaging in activities that would constitute modern slavery, and oblige our suppliers and brokers to implement procedures to prevent slavery or human trafficking further down the supply chain.
  • We are planning to check our suppliers and brokers, where appropriate, against a central register of published Modern Slavery and Human Trafficking Statements to monitor whether they have published a statement.
  • We continue to maintain systems and processes to support and protect whistle blowers.

SUPPLIER ADHERENCE TO OUR VALUES

We expect all those in our supply chain and contractors to comply with our value of zero tolerance to slavery and human trafficking.

We have a dedicated Compliance Officer and involvement from the following departments to ensure adherence to our values:

  • Legal.
  • Audit.
  • Compliance.
  • Procurement.

OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING

We will use the following measures to assess how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

· Completion of audits;

· Communication and personal contact with our suppliers to assess their understanding of, and compliance with, our expectations.

We are currently reviewing our audit provision to ensure that we are adequately monitoring and identifying risk in this area.

TRAINING

To ensure that all our staff are aware of Modern Slavery, appropriate training will be provided as necessary. This year we intend to roll out appropriate training for targeted staff. We have published the ERS Group Policy on Slavery and Human Trafficking on our intranet to inform our employees and to encourage them to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains.

 

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement for ERS DGB Limited and all companies within the ERS Group for the financial year ended 31 December 2018.

 

Signed  

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Ian Parker

ERS CEO

Date 7th December 2018